AI Governance Law Tracker

The FTC has signaled continued enforcement action against companies using AI in ways that constitute unfair or deceptive acts or practices under Section 5 of the FTC Act. Companies using AI in marketing, pricing, or customer-facing decisions face scrutiny independent of state AI laws.

The CFPB issued guidance clarifying that lenders using AI/ML models for credit decisions must provide specific, accurate reasons for adverse actions — "checklist" reasons are insufficient when the actual denial reason was an AI model output. Violations expose lenders to ECOA and FCRA liability.

The EEOC, DOJ, CFPB, and FTC issued a joint statement affirming that existing civil rights and consumer protection laws apply fully to AI systems. Employers using AI in hiring, promotion, or termination decisions face Title VII, ADEA, and ADA scrutiny regardless of whether the AI was built in-house or purchased from a vendor.

New York City's Department of Consumer and Worker Protection is actively enforcing Local Law 144 requirements for annual independent bias audits of automated employment decision tools. Employers using AI in hiring for NYC-based positions must have a current bias audit and public summary — penalties are $1,500 per day per violation.